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Case Law

Use of Well-Known Mark 'JIO' in Trading Name and Domain Constitutes Prima Facie Infringement: Bombay High Court

2025-11-29

Subject: Intellectual Property Law - Trademark Law

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Use of Well-Known Mark 'JIO' in Trading Name and Domain Constitutes Prima Facie Infringement: Bombay High Court

Supreme Today News Desk

Bombay High Court Grants Injunction to Reliance, Halts 'Jio Taxi' Service for Trademark Infringement

Mumbai: The Bombay High Court has granted an ad-interim injunction in favor of Reliance Industries Limited (RIL), restraining a Jharkhand-based taxi service from using the trade name "Jio Taxi" and the domain name www.jiotaxicab.com. The court, presided over by Justice Sharmila U. Deshmukh, found a strong prima facie case of trademark infringement and passing-off, emphasizing the well-known status of RIL's "JIO" mark.

Background of the Dispute

Reliance Industries Limited, a major Indian conglomerate, filed a suit against Abhay Kumar (Defendant No. 1), the proprietor of "Jio Taxi," and the domain registrar (Defendant No. 2). RIL alleged that the defendants were unlawfully using its registered and well-known trademark "JIO" to offer car rental and taxi services, thereby infringing on its statutory and common law rights.

Despite being served notice, the defendant, Abhay Kumar, refused to accept the service and did not appear before the court to contest the claims.

Reliance's Arguments

Counsel for Reliance, Mr. Bhagat, presented several key arguments to establish the company's rights and the defendant's infringement:

  • Prior Registration: RIL is the registered proprietor of the "JIO" trademark and its variants, with the earliest registration dating back to 2011. Crucially, the mark was registered in Class 39, which covers transport services, as early as 2012.
  • Well-Known Mark: The "JIO" brand has achieved significant recognition and goodwill through its extensive diversification into telecom, e-commerce (Ajio.com), and online retail (JioMart). The court acknowledged that "JIO" has been recognized as a well-known trademark.
  • Deceptive Similarity: RIL discovered the defendant's website in April 2025 and argued that the name "Jio Taxi" and the domain www.jiotaxicab.com were deceptively similar to its own mark, creating confusion among consumers.
  • Prior Rejection by Registry: A search of the Trade Marks Registry revealed that the defendant had previously applied to register the "JIO TAXI" mark in 2020, but the application was rejected, citing RIL's existing trademark as a conflict.

Court's Prima Facie Findings

Justice Deshmukh, after reviewing the evidence, concluded that RIL had successfully established a strong prima facie case for interim relief. The court's reasoning was based on several pivotal observations from the judgment:

> "The Defendant No. 1 is using the mark 'JIO TAXI' which subsumes the entire registered mark of the Plaintiff. The Defendant No. 1 is also infringing the registered mark by using it as part of its domain name and trading name."

The court noted that the defendant's mark was "deceptively similar" and that the prior rejection of the defendant's trademark application by the Registry further strengthened RIL's position. In a significant statement, the court observed:

> "There is no probable defense which could be available to the Defendant for using the well-known trade mark 'JIO'."

The Injunction Order

Based on these findings, the High Court passed a comprehensive ad-interim injunction restraining Defendant No. 1 from:

1. Offering car rental or any other services using the mark "JIO," the trading name "Jio Taxi," or the domain name www.jiotaxicab.com .

2. Using any mark or name identical or deceptively similar to "JIO" in a manner that would amount to passing off their services as those of Reliance.

Furthermore, the court directed the domain registrar (Defendant No. 2) to suspend the impugned domain name and disclose the full details of its registrant to Reliance.

The ad-interim relief will remain in effect until the next hearing, which is scheduled for December 16, 2025. This order serves as a strong reinforcement of the legal protection afforded to well-known trademarks against unauthorized adoption, particularly in the digital space.

#TrademarkInfringement #IPLaw #BombayHighCourt

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